Good afternoon, Mr. Chair, and honourable members of the committee.
It is a pleasure to be here today to provide CCSPA’s perspective on your review of the Pest Control Products Act.
My name is Shannon Coombs and I am the President of the Canadian Consumer Specialty Products Association. I have proudly represented this industry for 17 years and our many accomplishments as a proactive and responsible industry.
CCSPA is a national trade association that represents 35 member companies across Canada; collectively a $20-billion industry directly employing 12,000 Canadians in over 100 facilities. Our companies manufacture, process, package, and distribute consumer, industrial, and institutional specialty products, such as soaps and detergents, domestic pest control products, aerosols, hard surface disinfectants, deodorizers, and automotive chemicals, or as I call it, everything under the kitchen sink. I have provided the clerk with a copy of our one-pager that has a picture of our products. I am sure many of you have used them today.
Why are we here? CCSPA member companies that make domestic pest control products are regulated by the PCPA. Our final products are designed for consumers. We have personal insect repellents, ant traps, rodenticides, and wasp spray. The ingredients, end-use packaging, labels, advertising, and reporting are all regulated under this act. They meet the rigorous requirements of the Pest Control Products Act for safety, value, and merit. I brought a small sample of the products that some of our members make: bedbug spray, personal insect repellent, ant traps, and antibacterial cleaner. Products that are classified as sanitizers are also pest control products in Canada.
To put the domestic sales of pest control products in perspective—I know earlier this week you had the agriculture sector here—I would offer the following statistics. In the Pest Control Product Sales Report for 2011 it states that domestic pesticides account for 4.6% of all pesticide sales in Canada. Domestic products, are classified as antimicrobials, insecticides, and herbicides. Antimicrobials used primarily for swimming pools and spas account for almost 76% of all domestic pesticide sales. Insecticides account for 18% and herbicides 5%. It should be noted that the top 10 active ingredients account for 84% of the domestic sector of pesticides sold. Seven of the top 10 are pool chemicals.
In preparation for the presentation today I went back to the presentation that I made before this committee in April of 2002. I thought it would be helpful to reflect on where we were then and where we are now with eight years of experience with the legislation. Pesticides continue to make headline news and often for the wrong reasons. The message that the products are beneficial continues to get lost, which is unfortunate. That was the state of the issue then and it still is now.
The story is very different because of the modern legislation that this committee passed in 2002. The act put into place a rigorous, science-based system with checks and balances that serves Canadians well. They can be confident that the products they use in their homes to protect themselves from insects or weeds do the job. They are safe and they are effective.
Let’s evaluate the agency against the criticisms from 2002 and where we are today.
In regard to products under re-evaluation, there were 401 active ingredients that were identified in 1998 for re-evaluation. These re-evaluations are almost complete. The 15-year review cycle for re-evaluations commenced in 2006 when the act came into force. The approach for the 401 active ingredients was to conduct scientifically based reviews, to manage the workload effectively, and to work with industry to ensure that there were product changes, or label changes, or possibly even discontinuations of products. This is a very successful outcome of the work of the agency and the new act.
In regard to performance timelines, in 2002 the lack of the performance of the agency was at an all-time fever pitch when a 1998 report, the Nephin report, said that the agency was taking 40% longer than its counterparts to complete its reviews. This is no longer the case. The agency has worked very hard to develop performance standards and adhere to them. In the last three years it has met its performance targets for almost all submission types.
Since 2002 the PMRA has employed effective management tools, such as electronic submissions and pre-submission consultations, and addressed paper burden and unique Canadian data requirements to help our members bring innovative consumer products to market.
In 2002 sales reporting and the lack of transparency on how product registrations were conducted was an area that garnered a fair amount of criticism from stakeholders. Transparency is now a legislated requirement. There are registration decisions, products under review, the public registry, products being re-evaluated, comments solicited from the public on those actions, and annual sales reporting, plus a diligent process for collecting, evaluating, and reporting on incidents.
In our opinion, the PMRA raises the bar globally with all of these PCPA initiatives.
As an extension of the transparency initiatives, I would also like to mention the outreach conducted by the PMRA to various stakeholders through the work of the minister's pest management advisory council, an economic management advisory committee, and other work that it does with the federal, provincial and territorial committee on pest management and pesticides.
Those are just a few examples, but overall I believe we have a very modern piece of legislation that allows technology to come to Canada—products that are important to consumers—and allows industry to be competitive.
A predictable, science-based system exists and we all need a better way to communicate its successes to Canadians. There's been a great deal of improvement by the PMRA since 2002, when I appeared on the proposed legislation.
While CCSPA is not proposing any amendments to the PCPA, I would offer one observation of the PMRA, and it is its lack of self-promotion. In the summer of 2011, CCSPA conducted consumer polling in the province of British Columbia on the subject of pest control products. In that polling, 71% of respondents stated that they were aware of Health Canada's role in approving pesticides in Canada, and 69% of respondents trusted Health Canada's regulation and approval of pesticides. To me this demonstrates that when Canadians know about Health Canada's role in the regulatory process, they have confidence in the regulatory process. Health Canada should be doing more to communicate the work that it is doing to protect the health and the environment of Canadians as it relates to pest control products.
As the committee prepares its report, you may wish to also comment on the PMRA's need to increase its communications and offer a recommendation, if you are of the same opinion.
Mr. Chair, I thank you for the opportunity to present today. I will be willing to take any questions the members may have.